GAM is committed to protecting and safeguarding the personal data of current, prospective and former clients in accordance with the provisions of the Ordinance.
Within GAM your personal data will be transmitted and stored in a protected environment. We will take all reasonable steps to ensure that your personal data will not be seen by any third parties other than those which GAM has engaged in order to provide services to you or to GAM. We will only disclose your data to other third parties if compelled to do so for legal or regulatory purposes. We will not supply any information about you to anyone unless we believe it is lawful to do so.
If you register with us on the GAM website (the “Site”) your registration data will be used to determine which funds and services are available to you in accordance with your professional status and place of residence. GAM does not collect personal data relating to you from the Site except when provided voluntarily by you.
GAM has various security provisions in place to ensure the privacy of your personal information. However, GAM accepts no responsibility or liability for the security of your data whilst in transit from you via the internet to us. If you prefer, you may choose another means to communicate with us, where you consider it appropriate.
The Site may include hyperlinks to other third party websites that are not operated or controlled by GAM. Once you leave our Site, GAM is not responsible for the content or the privacy practices of third party websites.
A cookie is a small text file that is sent to your computer, or other device, by the websites that you visit. They are widely used to monitor traffic to sites, and to enable certain functionality such as personalising websites to your interests or preferences.
Any personal data provided by you through the Site is provided voluntarily by you.
GAM may use the personal data which you provide for any one or more of the following purposes:
GAM will not request disclosure of sensitive personal data through this Site (such as data relating to your ethnic origin or religion) but if you choose to provide such data, GAM will assume that such data are provided by you voluntarily and can be used for the above purposes.
GAM will not transfer any personal data it collects about you to third parties except:
GAM will not sell, share, rent or otherwise disclose or transfer your personal information to others for monetary gains.
GAM may use your personal data in direct marketing and GAM requires your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
If you do not want GAM to use your data or transfer them to a third party for use in direct marketing, you may exercise your opt-out right by notifying the Data Protection Officer of GAM Hong Kong Limited.
In addition to one-to-one email messages from client managers or other contacts you have at GAM, you may also be subscribed to our centralised mailing lists. This will only happen upon receiving your written consent. You can unsubscribe from our mailings at any point. Every email has several options to unsubscribe at the end of the message. Alternatively, you can ask your GAM contact to remove you from specific mailings. If you are a client of GAM or invested in a GAM fund, you may receive fund reporting mailings (e.g. fund fact sheets, holding reports, risk reports, performance updates).
GAM may record or monitor telephone conversations and email correspondence between you and GAM to monitor the effectiveness of security arrangements, to enable compliance with applicable laws and regulations, and to maintain and improve the quality of GAM services.
GAM will only retain your personal information for as long as is needed to comply with any applicable laws and regulations.
In accordance with the terms of the Ordinance, you have the right to:
In accordance with the terms of the Ordinance, GAM has the right to charge a reasonable fee for the processing of any data access request.
If you do not wish your personal data to be used for direct marketing purposes, you may exercise your opt-out right at any time by writing to the Data Protection Officer. The Data Protection Officer is also the individual to whom requests for access to data, correction of inaccurate data, or for information about policies and practices and kinds of data held, should be addressed. Communication to the Data Protection Officer should be addressed to:
The Data Protection Officer
c/o Head of Legal & Compliance
GAM Hong Kong Limited
23/F, Lee Garden One
33 Hysan Avenue